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employer, Unisys. Neither petitioner nor his attorney submitted
a brief on petitioner’s behalf or presented any frivolous
arguments. The Court, therefore, concludes that it is not
appropriate to impose a penalty in the instant case, but the
Court explicitly admonishes petitioner that he may, in the
future, be subject to a penalty under section 6673 for any
proceedings instituted or maintained primarily for delay or for
any proceedings which are frivolous or groundless.
The Court has considered all of petitioner’s contentions,
arguments, requests, and statements. To the extent not discussed
herein, we conclude that they are meritless, moot, or irrelevant.
To reflect the foregoing and concessions made by respondent,
An appropriate decision
will be entered for respondent
with respect to the deficiency
and additions to tax under
sections 6651(a)(1) and 6654
and for petitioner with
respect to the addition to tax
under section 6651(a)(2).
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Last modified: May 25, 2011